Code of Conduct

Baxter’s Code of Conduct defines the core principles that govern employee behavior and how the company conducts its business, as well as provides tools and resources to help employees comply. The Code applies to Baxter’s Board of Directors and all of its employees, including the company’s chief executive officer and other senior management. Available in multiple languages, the Code builds on Baxter’s long-standing commitment to leadership in ethical business practices. It covers topics such as:

Protection and use of company assets

Accurate recordkeeping

Competitive and confidential information

Sales and marketing practices

Anticorruption

Insider trading

Life Sciences Ethics

Conflicts of interest

Gifts

Trade compliance

The Code includes Baxter’s Global Interactions Policy, which covers how the company’s employees, contractors, agents and third parties conduct themselves with government officials.

Additionally, the Code requires prompt reporting of suspected misconduct and outlines the consequences of failure to comply with applicable laws or Baxter’s policies and procedures. The company provides ongoing training to keep employees informed about Baxter’s ethics and compliance policies, and provides other tools and resources.